Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT addressed transfer pricing and tax deduction matters. In the TP adjustment, the tribunal remanded the case to the TPO/AO to determine arm's length pricing using TNNM method, with a 3% tolerance range for operating margin. For weighted deduction under section 35(2AB), the tribunal allowed the assessee's claim consistently with a prior year's order. Regarding additional depreciation under section 32(iia), the tribunal directed the AO to comply with DRP's instructions and allow the depreciation claim, criticizing the AO's failure to implement previous directions. The decision emphasizes procedural compliance and consistent interpretation of tax regulations.
The ITAT addressed transfer pricing and tax deduction matters. In the TP adjustment, the tribunal remanded the case to the TPO/AO to determine arm's length pricing using TNNM method, with a 3% tolerance range for operating margin. For weighted deduction under section 35(2AB), the tribunal allowed the assessee's claim consistently with a prior year's order. Regarding additional depreciation under section 32(iia), the tribunal directed the AO to comply with DRP's instructions and allow the depreciation claim, criticizing the AO's failure to implement previous directions. The decision emphasizes procedural compliance and consistent interpretation of tax regulations.
Note: It is a system-generated summary and is for quick reference only.